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Consequences of the New UK Tax Exemption System: Evidence from Micro-level Data

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  • Peter Egger
  • Valeria Merlo
  • Martin Ruf
  • Georg Wamser

Abstract

Until 2009, the United Kingdom operated a system of worldwide taxation. Taxation of foreign income was deferred until repatriated as dividends, leaving UK-owned multinational firms the possibility of avoiding UK taxation by delaying dividend payments and keeping earnings abroad. In 2009, the UK switched to a system under which all foreign-earned income is exempted from taxation. This fundamental change had a number of straightforward implications for UK-owned multinational firms and particularly changed incentives to repatriate profits. This paper assesses the effects of the reform on the foreign affiliates of UK-owned multinational firms. We use data provided by Bureau van Dijk on 61,738 foreign affiliates located in one of 29 European countries to estimate the impact of the reform on the repatriation pattern and other outcomes of UK-owned affiliates. We use an identification approach that quasi-randomizes over the country of residence of the ultimate firm owners, allowing us to compare outcomes of treated UK-owned foreign affiliates to control non-UK-owned foreign affiliates. Our results suggest that the switch to tax exemption not only changed dividend repatriation behavior of firms but also the conditions under which foreign entities operate in general, for instance, with regard to investment behavior.

Suggested Citation

  • Peter Egger & Valeria Merlo & Martin Ruf & Georg Wamser, 2012. "Consequences of the New UK Tax Exemption System: Evidence from Micro-level Data," CESifo Working Paper Series 3942, CESifo Group Munich.
  • Handle: RePEc:ces:ceswps:_3942
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    References listed on IDEAS

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    Cited by:

    1. Bradley, Sebastien & Dauchy, Estelle & Hasegawa, Makoto, 2013. "Investor Valuations of Japan's Adoption of a Territorial Tax Regime: Quantifying the Direct and Competitive Effects of International Tax Reform," School of Economics Working Paper Series 2013-2, LeBow College of Business, Drexel University, revised 15 Sep 2014.
    2. Peter Egger & Michael Stimmelmayr, 2017. "Taxation and the Multinational Firm," CESifo Working Paper Series 6384, CESifo Group Munich.
    3. Harendt, Christoph & Dreßler, Daniel & Overesch, Michael, 2016. "The Impact of Tax Treaties and Repatriation Taxes on FDI Revisited," Annual Conference 2016 (Augsburg): Demographic Change 145588, Verein für Socialpolitik / German Economic Association.
    4. Li Liu & Tim Schmidt-Eisenlohr & Dongxian Guo, 2017. "International Transfer Pricing and Tax Avoidance : Evidence from Linked Trade-Tax Statistics in the UK," International Finance Discussion Papers 1214, Board of Governors of the Federal Reserve System (U.S.).
    5. Hasegawa, Makoto & Kiyota, Kozo, 2017. "The effect of moving to a territorial tax system on profit repatriation: Evidence from Japan," Journal of Public Economics, Elsevier, vol. 153(C), pages 92-110.
    6. Overesch Michael, 2016. "Steuervermeidung multinationaler Unternehmen," Perspektiven der Wirtschaftspolitik, De Gruyter, vol. 17(2), pages 129-143, July.
    7. Céline Azémar & Dhammika Dharmapala, 2016. "Tax Sparing, FDI, and Foreign Aid: Evidence from Territorial Tax Reforms," CESifo Working Paper Series 5874, CESifo Group Munich.
    8. Michael Overesch & Sabine Schenkelberg & Georg Wamser, 2018. "Do US Firms Pay Less Tax than their European Peers? On Firm Characteristics, Profit Shifting Opportunities, and Tax Legislation as Determinants of Tax Differentials," CESifo Working Paper Series 6960, CESifo Group Munich.

    More about this item

    Keywords

    UK Tax Reform 2009; tax exemption system; dividend exemption; foreign direct investment;

    JEL classification:

    • F23 - International Economics - - International Factor Movements and International Business - - - Multinational Firms; International Business
    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies

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